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HMRC internal manual

Capital Gains Manual

Depreciatory intra-group dividends: drain out dividend scheme

Profits are chargeable profits if they satisfy all the following three tests

  • the ‘asset transaction’ test, see CG46830+
  • the ‘asset retention’ test, see CG46832+
  • the ‘asset severance’ test, see CG46834; see also CG46835-6 for the amendments in FA 1999.

Finance Act 2011 introduced a new Targeted Anti-Avoidance Rule for disposals of shares and securities by companies on or after 19 July 2011. See CG48500+.